Growing Wealth by Avoiding Fragility

Privacy Policy and Data Protection Notice

Emmoni Capital Limited (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

Last updated: 31 Dec 2025

1) Who we are

Controller: Emmoni Capital Limited (Irish private limited company)
CRO number: 737410
Registered office: Block 3, Harcourt Centre, Dublin D02 A339
Website: www.emmonicapital.com

We act as an alternative investment fund manager (“AIFM”). As we are below the thresholds set under the applicable AIFM framework, we are registered with the Central Bank of Ireland as a sub-threshold AIFM. 

2) How to contact us

Data protection contact:
Email: info <at> emmonicapital.com

3) Who this notice applies to

This notice applies to personal data we process about:

  • investors and prospective investors (including beneficial owners and controlling persons);

  • directors, officers, employees and representatives of investors or counterparties;

  • intermediaries (e.g., placement agents, distributors), service provider contacts;

  • website visitors and people who contact us.

4) What personal data we collect

We may collect the following categories of personal data (depending on your relationship with us):

Identity & contact: name, title, date of birth, nationality, address, email, phone.
Investor / relationship: subscription and redemption details, holdings, correspondence, investor classification information.
Financial: bank account/payment details, transaction history, confirmations, invoices/fees (where applicable).
Tax & regulatory reporting: tax residence, TIN/SSN equivalents, FATCA/CRS self-certifications and related information. 
KYC / AML / screening: ID documents, proof of address, source of funds/wealth, beneficial ownership data, sanctions/PEP screening results, ongoing monitoring notes.
Communications: emails, call notes, meeting notes, complaint records.
Website/technical: IP address, device/browser info, logs, cookie identifiers and analytics data (where used).

5) Where we get your personal data from

We obtain personal data from:

  • you (forms, onboarding, communications, website);

  • your representatives, nominees, intermediaries, or professional advisers;

  • fund/service providers (e.g., administrator/transfer agent, distributors);

  • identity verification, screening and fraud-prevention providers;

  • public sources (e.g., company registers, sanctions lists) where relevant.

If we receive your data from a third party (not from you directly), we provide the required transparency information in line with GDPR obligations. 

6) How and why we use personal data (purposes and legal bases)

We only process personal data where permitted by GDPR (e.g., contract, legal obligation, legitimate interests, consent). 

A. Onboarding and investor relationship management

Purpose: assess eligibility, onboarding, maintaining registers, subscriptions/redemptions, investor services, communications.
Legal basis: performance of a contract / steps prior to contract; legitimate interests in operating and administering our business. 

B. Regulatory compliance (including engagement with regulators)

Purpose: meet legal/regulatory requirements applicable to our role and business (including reporting, audits, governance, responding to regulator queries).
Legal basis: legal obligation; legitimate interests. 

C. Anti-money laundering and counter-terrorist financing (AML/CFT)

Purpose: customer due diligence (CDD), verification, screening, ongoing monitoring, recordkeeping, and making reports to authorities where required.
Legal basis: legal obligation; substantial public interest where applicable.

Recordkeeping: Irish AML law includes record retention obligations (generally not less than 5 years) and may allow additional retention where directed by competent authorities in specific circumstances.

D. Tax transparency / automatic exchange of information (FATCA / CRS / DAC2)

Purpose: collect and report required information to the Irish Revenue Commissioners and facilitate exchange with relevant jurisdictions where applicable. 
Legal basis: legal obligation.

E. Running our business (operations, risk, security, legal)

Purpose: managing relationships with service providers and counterparties, corporate governance, risk management, IT/security, legal claims, professional advice.
Legal basis: legitimate interests; legal obligation (where applicable).

F. Marketing and updates (if applicable)

Purpose: send invitations, updates, or publications relevant to our business.
Legal basis: consent where required by law, otherwise legitimate interests (as permitted). You can opt out at any time.

7) Special category data and criminal offence data

We do not seek to collect special category data (e.g., health data) unless necessary. In limited cases, AML/CFT processes may involve information that is treated as sensitive or relates to criminal offence/conviction data (e.g., screening outcomes). Where required, we apply appropriate safeguards and only process such data to the extent permitted by law.

8) Who we share personal data with

We may share personal data with:

  • Fund/service providers: administrators, transfer agents, depositaries/custodians, brokers, distributors/placement agents, IT/cloud hosting, cybersecurity providers, document management providers;

  • Professional advisers: legal advisers, auditors, accountants, tax advisers;

  • Regulators and authorities: including the Central Bank of Ireland, law enforcement, courts, tax authorities; 

  • Irish Revenue Commissioners for FATCA/CRS/DAC2 reporting and onward exchange where applicable.

We only share data where necessary for the purposes described above and subject to appropriate contractual and security measures.

9) International transfers

Some recipients may be located outside the EEA/UK. Where we transfer personal data internationally, we will ensure an appropriate transfer mechanism is in place (e.g., adequacy decision or Standard Contractual Clauses with supplementary measures as required).

10) How long we keep your personal data

We keep personal data only for as long as necessary for the purposes set out in this notice, including to meet legal, regulatory, tax, and AML obligations.

In particular, Irish AML law requires designated persons to retain certain records for at least 5 years (and may permit additional retention in specified circumstances). 

We maintain a retention schedule and will provide high-level retention information on request.

11) Cookies and similar technologies

If our website uses cookies or similar technologies, we will provide a cookie banner/notice and (where required) obtain consent for non-essential cookies.

In Ireland, cookie rules arise under the ePrivacy Regulations (S.I. No. 336/2011), and guidance is published by the Data Protection Commission. 

See our Cookie Policy.

12) Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. No system is completely secure, but we work to protect your data and review our controls regularly.

13) Your data protection rights

Subject to certain conditions and exemptions, you have rights including:

  • access, rectification, erasure;

  • restriction and objection;

  • data portability;

  • rights relating to automated decision-making/profiling (if applicable).

Under GDPR, you also have the right to be informed through notices like this one. 

To exercise your rights, contact us using the details in Section 2.

14) Complaints

If you have concerns, please contact us first and we will try to resolve them.

You also have the right to lodge a complaint with Ireland’s supervisory authority, the Data Protection Commission (DPC). The DPC provides complaint and contact channels (including webform and email). 

15) Third-party websites

Our website may contain links to third-party sites. We are not responsible for their privacy practices. Please review their privacy notices.

16) Changes to this notice

We may update this notice from time to time. We will post the latest version on our website and update the “Last updated” date above.

 

Terms of Use

 

Legal Information

This website is issued by Emmoni Capital Limited (“Emmoni” / “we”/ “us”), registered as a sub-threshold Alternative Investment Fund Manager, under Regulation 4 of the AIFMD, with the Central Bank of Ireland (“CBI”) with registration number 509758.

When accessing any information or material made available on this website (“site”) you accept and agree to comply with the terms and conditions as set out below. The site is intended exclusively for the use of accredited or qualified investors in the US and Ireland, respectively.

Information on this site

This site is provided for general information purposes only. It does not constitute a recommendation, offer or solicitation to enter into any contract or agreement to provide any investment services, or to apply for, or buy any investments, securities or funds nor a recommendation regarding the suitability of any Emmoni funds or services for any particular user. None of the services, investments or funds referred to in this site are available for sale or use in any jurisdiction where such activity is prohibited.

Funds

The offering of interests in the funds described on this Site is generally subject to restrictions in the United States and Ireland:
 

In the United States (US), interests are offered only to persons who are “Accredited Investors” as defined in Rule 501(a) of Regulation D under the US Securities Act of 1933, and generally only to “Qualified Purchasers” as defined in Section 2(a)(51) of the Investment Company Act of 1940.

 
In Ireland, interests are offered only to persons who are deemed “Qualified Investors”  as defined in Annex II of Markets in Financial Instruments Directive 2014/16/EU.

Applications to invest in any fund referred to on this site, must only be made on the basis of the offering documents relating to the specific investment. 
 

Risk Warning

Investors should consider carefully all specific risks of the funds described in this site carefully prior to making an investment. The risks relevant for each fund are described within the applicable fund documentation for each fund. Some general risks to consider include: Past performance of an investment is not a guide to any future performance; the value of investments and any income generated may go down as well as up and is not guaranteed; changes in exchange rates may have an adverse effect on the value, price or income of investments. Please see the relevant fund documentation for full details of applicable risks. 

Nothing in this site constitutes any investment, legal, tax and other advice and it is not to be relied upon in making any investment decision. You should take appropriate professional advice prior to making any investment decision on the basis of the content on this site.

No Warranty

Although we make reasonable efforts to update the content and information on this site, we make no guarantees, warranties or representations (whether express or implied) that the content will be up to date, accurate or complete. 

We do not guarantee that this site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the site and we reserve the right to amend or alter any of the information or contents of this site at any time without notice. No liability is accepted by us for such changes or for the site or any content not being available.

Viruses and Misuse

We do not guarantee that the site will be secure or free from bugs or viruses. You are responsible for configuring the information technology you use to access the site and you should use your own virus protection software.

You must not post or transmit to or from the site anything which is technically harmful (including, without limitation) viruses, Trojan horses, worms, logic bombs or other material that is malicious or technologically harmful. You must not misuse this site (including, without limitation by hacking or a denial-of-service attack).  We will co-operate fully with any law enforcement authorities or court order requesting or directing us to disclose your identity. 

Linked/External Websites

This site may contain links to other websites maintained by third parties. If you use these links you leave this site. These links are provided for your information only and should not be interpreted as Emmoni’s approval of those linked websites or any resources contained in them. Emmoni has no control over those third parties, the content of those websites or resources. You use such links at your own risk.

Liability

We do not accept any responsibility arising in any way (including by reason of negligence) for errors in, or omissions from, the content or information in this site. 

We do not accept any liability for any loss or damage, however caused, as a result of you relying on any information on the site or if you are unable to access the site.

We are not responsible if the means of communication you use to access the site, to send information to us or to receive information from us does not work properly. The internet is not a totally reliable and secure medium of communication. We accept no liability for the security or confidentiality of information transmitted in this way and any such transmission of information shall be at your own risk.

We do not exclude or limit in any way our liability to you where it would be unlawful to do so.

Privacy and Cookies

All information provided to Emmoni through this site is used solely by Emmoni, its affiliates and employees only. By using this website please be aware that information we hold about you may be disclosed to any regulatory authority to which Emmoni is subject, or to any person legally empowered to require such information. 

When you browse the website we use cookies to allow our site to remember your preferences and whether you accept our terms of use. We do not use cookies that provide information to advertising networks or those who track your activity across multiple sites. 

This website also uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Emmoni’s Privacy Policy and information about Emmoni’s use of data and cookies can be found on Emmoni’s Privacy and Cookie pages. By continuing to use this website you are consenting to the website’s use of cookies and you will be deemed to have accepted Emmoni’s Privacy Policy and Cookie Policy.

Copyright

Emmoni owns or licenses all of the intellectual property rights in the site, and in the materials published on it. These works are protected by copyright. All such rights are reserved. You may print off one copy, and may download extracts, of any page(s) from our site for your personal use. Under no circumstances should any information be modified, copied, reproduced, or redistributed without our prior written consent. 

Law

These terms, their subject matter and formation (and any non-contractual dispute) are governed by the laws of Ireland. Disputes arising in connection with them shall be subject to the exclusive jurisdiction of the courts of Ireland.

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